Huggett v. Commissioner
United States Board of Tax Appeals
Petitioner and his wife filed joint returns for 1925 and 1926. The wife's grandmother died testate in 1912, giving her daughter a life interest in half the income from securities, with a part of the remainder over to the granddaughter, the petitioner's wife. The life tenant died May 15, 1924. In 1925 and 1926 petitioner's wife sold stock distributed to her as remainderman.
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Petitioner and his wife filed joint returns for 1925 and 1926. The wife's grandmother died testate in 1912, giving her daughter a life interest in half the income from securities, with a part of the remainder over to the granddaughter, the petitioner's wife. The life tenant died May 15, 1924. In 1925 and 1926 petitioner's wife sold stock distributed to her as remainderman. Held, following Rodman E. Griscom,22 B.T.A. 979, that March 1, 1913, is the basic date for determining gain or loss. Held, further, that the basis is the value of the remainderman's interest as distinguished from the value…
1Opinion of the Court
*671OPINION.
Aeundell :
Muriel D. Huggett, wife of the petitioner, was named as a remainderman in the will of her grandmother, who died in 1912, subject to a life estate in Mrs. Huggett’s mother. On the termination of the life estate in 1924, securities forming a part of the original estate were distributed to Mrs. Huggett as remainderman in accordance with the will. These same securities (disregarding change in form following reorganization) were sold by Mrs. Huggett in 1925 and 1926 for more than their March 1, 1913, value and more than their value at the time of distribution in 1924. Petitioner…
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- Brewster v. GageSupreme Court of the United States · 1930
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- Coolidge v. LongSupreme Court of the United States · 1931
- Simpson v. United StatesSupreme Court of the United States · 1920
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3Cited by6 opinions
- Warner v. CommissionerUnited States Board of Tax Appeals · 1933
- Beers v. CommissionerUnited States Board of Tax Appeals · 1934
- Vale v. CommissionerUnited States Board of Tax Appeals · 1934
- Huggett v. CommissionerUnited States Board of Tax Appeals · 1931
- Vale v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.